EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`
`References cited herein:
` U.S. Pat. No. 6,853,142 (“’142 Patent”)
`
` D.V. Mozgrin, et al, High-Current Low-Pressure Quasi-Stationary Discharge in a
`Magnetic Field: Experimental Research, Plasma Physics Reports, Vol. 21, No. 5, 1995
`(“Mozgrin”)
`
` A. A. Kudryavtsev, et al, Ionization relaxation in a plasma produced by a pulsed inert-gas
`discharge, Sov. Phys. Tech. Phys. 28(1), January 1983 (“Kudryavtsev”)
`
` Dennis M. Manos & Daniel L. Flamm, Plasma Etching: An Introduction, Academic Press
`1989 (“Manos”)
`
` Milton Ohring, The Material Science of Thin Films, Academic Press, 1992 (“Ohring”)
`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`[21pre.] An apparatus for
`generating a strongly-ionized
`plasma, the apparatus
`comprising:
`
`[21a.] an anode;
`
`Mozgrin in view of Kudryavtsev
`
`The combination of Mozgrin and Kudryavstev discloses an
`apparatus for generating a strongly-ionized plasma.
`
`‘142 Patent at claim 18 (“wherein the peak plasma density
`of the strongly-ionized plasma is greater than about
`1012 cm˗3”)
`
`Mozgrin at Fig 1
`
`Mozgrin at 400, right col, ¶ 4 (“To study the high-current
`forms of the discharge, we used two types of devices: a
`planar magnetron and a system with specifically shaped
`hollow electrodes.”)
`
`Mozgrin at 401, right col, ¶2 (“For pre-ionization … the
`initial plasma density in the 109 – 1011 cm-3 range.”)
`
`Mozgrin at 409, left col, ¶ 4 (“The implementation of the
`high-current magnetron discharge (regime 2) in sputtering
`… plasma density (exceeding 2x1013 cm-3).”)
`
`Mozgrin at 409, left col, ¶5 (“The high-current diffuse
`discharge (regime 3) is useful for producing large-volume
`uniform dense plasmas ni  1.5x1015cm-3…”).
`The combination of Mozgrin and Kudryavstev discloses
`
`‘142 Patent at 2:21-22 (“FIG. 1 illustrates a cross-sectional
`view of a known plasma generating apparatus 100…”)
`
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`[21b.] a cathode that is
`positioned adjacent to the anode
`and forming a gap there
`between;
`
`[21c.] an ionization source that
`generates a weakly-ionized
`plasma proximate to the cathode,
`the weakly-ionized plasma
`reducing the probability of
`developing an electrical
`breakdown condition between
`the anode and the cathode; and
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`’142 Patent at 2:45-46 (“An anode 130 is positioned in the
`vacuum chamber 104 proximate to the cathode 114.”)
`
`Mozgrin at Fig. 1
`
`Mozgrin at 401, Fig. 1 caption (“Fig. 1… (1) Cathode; (2)
`anode; …”)
`
`The combination of Mozgrin and Kudryavstev discloses a
`cathode that is positioned adjacent to the anode and
`forming a gap there between.
`
`‘142 Patent at 2:21-22 (“FIG. 1 illustrates a cross-sectional
`view of a known plasma generating apparatus 100…”)
`
`’142 Patent at 2:45-46 (“An anode 130 is positioned in the
`vacuum chamber 104 proximate to the cathode 114.”)
`
`Mozgrin at Fig. 1
`
`Mozgrin at 401, Fig. 1 caption (“Fig. 1… (1) Cathode; (2)
`anode; …”)
`
`The combination of Mozgrin and Kudryavstev discloses an
`ionization source that generates a weakly-ionized plasma
`proximate to the cathode, the weakly-ionized plasma
`reducing the probability of developing an electrical
`breakdown condition between the anode and the cathode.
`
`‘142 Patent at 5:18-19 (“The weakly-ionized plasma is also
`referred to as a pre-ionized plasma.”)
`
`‘142 Patent at claim 17 (“wherein the peak plasma density
`of the weakly-ionized plasma is less than about 1012 cm˗3”)
`
`Mozgrin at Figs. 1, 2, 3, 6, 7
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had
`an annular shape and was adjacent to the cathode.”)
`
`Mozgrin at 401, left col, ¶ 4 (“[A]pplying a square voltage
`pulse to the discharge gap which was filled up with either
`neutral or pre-ionized gas.”)
`
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`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`[21d.] a power supply that
`produces an electric field across
`the gap, the electric field
`generating excited atoms in the
`weakly-ionized plasma and
`generating secondary electrons
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`Mozgrin at 402, right col, ¶2 (“Figure 3 shows typical
`voltage and current oscillograms.… Part I in the voltage
`oscillogram represents the voltage of the stationary
`discharge (pre-ionization stage).”)
`
`Mozgrin at 401, right col, ¶2 (“[f]or pre-ionization, we
`used a stationary magnetron discharge; … provided the
`initial plasma density in the 109 – 1011 cm˗3 range.”)
`
`Mozgrin at 400, right col, ¶ 3 (“We investigated the
`discharge regimes in various gas mixtures at 10-3 – 10
`torr…”)
`
`Mozgrin at 402, ¶ spanning left and right cols (“We studied
`the high-current discharge in wide ranges of discharge
`current…and operating pressure…using various gases (Ar,
`N2, SF6, and H2) or their mixtures of various
`composition…”)
`
`Mozgrin at 406, right col, ¶3 (“pre-ionization was not
`necessary; however, in this case, the probability of
`discharge transferring to arc mode increased.”)
`
`Mozgrin at 400, left col, ¶ 3 (“Some experiments on
`magnetron systems of various geometry showed that
`discharge regimes which do not transit to arcs can be
`obtained even at high currents.”)
`
`Background:
`
`Manos at 231 (“We shall … [include] information on
`unipolar arcs. These are a problem…”)
`
`Manos at 237 (“When such an arc occurs, the metal object
`is melted at the arc spot. The metal is explosively
`released…. How does one prevent such an arc? There are
`several methods…”)
`
`The combination of Mozgrin and Kudryavstev discloses a
`power supply that produces an electric field across the gap,
`the electric field generating excited atoms in the weakly-
`ionized plasma and generating secondary electrons from
`the cathode, the secondary electrons ionizing the excited
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`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`from the cathode, the secondary
`electrons ionizing the excited
`atoms, thereby creating the
`strongly-ionized plasma.
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`atoms, thereby creating the strongly-ionized plasma.
`
`‘142 Patent at 1:41-43 (“Magnetron sputtering systems use
`magnetic fields that are shaped to trap and to concentrate
`secondary electrons, which are produced by ion
`bombardment of the target surface.”)
`
`‘142 Patent at 1:37-40 (“The plasma is replenished by
`electron-ion pairs formed by the collision of neutral
`molecules with secondary electrons generated at the target
`surface.”)
`
`Mozgrin at Figs. 1, 2, 3
`
`Mozgrin at 402, right col, ¶ 2 (“Part 1 in the voltage
`oscillogram represents the voltage of the stationary
`discharge (pre-ionization stage).”)
`
`Mozgrin at 401, right col, ¶ 1 (“Thus, the supply unit was
`made providing square voltage and current pulses with
`[rise] times (leading edge) of 5 – 60 µs…”)
`
`Mozgrin at 401, ¶ spanning left and right cols (“[d]esigning
`the [pulsed supply] unit, we took into account the
`dependences which had been obtained in [Kudryavtsev] of
`ionization relaxation on pre-ionization parameters,
`pressure, and pulse voltage amplitude.”)
`
`Mozgrin 403, right col, ¶4 (“Regime 2 was characterized
`by intense cathode sputtering due to both high energy and
`density of ion flow.”)
`
`Kudryavtsev at Figs. 1, 6
`
`Kudryavtsev at 34, right col, ¶ 4 (“[s]ince the effects
`studied in this work are characteristic of ionization
`whenever a field is suddenly applied to a weakly ionized
`gas, they must be allowed for when studying emission
`mechanisms in pulsed gas lasers, gas breakdown, laser
`sparks, etc.”)
`
`Kudryavtsev at 31, right col, ¶ 6 (“For nearly stationary n2
`[excited atom density] values … there is an explosive
`increase in ne [plasma density]. The subsequent increase in
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`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`ne then reaches its maximum value, equal to the rate of
`excitation [equation omitted], which is several orders of
`magnitude greater than the ionization rate during the initial
`stage.”)
`
`Kudryavtsev at 31, right col, ¶ 7 (“The behavior of the
`increase in ne with time thus enables us to arbitrarily divide
`the ionization process into two stages, which we will call
`the slow and fast growth stages. Fig. 1 illustrates the
`relationships between the main electron currents in terms
`of the atomic energy levels during the slow and fast
`stages.”)
`
`Kudryavtsev at Abstract (“in a pulsed inert-gas discharge
`plasma at moderate pressures… [i]t is shown that the
`electron density increases explosively in time due to
`accumulation of atoms in the lowest excited states.”)
`
`Kudryavtsev at Equation 1
`
`Kudryavtsev at 30, right col, last ¶ (“n2, and ne are the
`atomic densities in the … first excited states and the
`electron density, respectively … 2e [is] the rate
`coefficient[]….”)
`
`See evidence cited in limitation [1pre] of claim 1.
`
`It would have been obvious to one of ordinary skill to
`combine Mozgrin with Kudryavtsev. Mozgrin itself cites
`Kudryavtsev. Moreover, Mozgrin explicitly notes that it
`was designed in accordance with Kudryavtsev. Mozgrin at
`401, ¶ spanning left and right columns (“Designing the
`[pulsed supply] unit, we took into account the dependences
`which had been obtained in [Kudryavtsev].”). Further,
`Kudryavtsev states, “[s]ince the effects studied in this work
`are characteristic of ionization whenever a field is suddenly
`applied to a weakly ionized gas, they must be allowed for
`when studying emission mechanisms in pulsed gas lasers,
`gas breakdown, laser sparks, etc.” Kudryavtsev at 34, right
`col, ¶ 4. Because Mozgrin applies voltage pulses that
`“suddenly generate an electric field,” one of ordinary skill
`reading Mozgrin would have been motivated to consider
`Kudryavtsev to further appreciate the effects of applying
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`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`22. The apparatus of claim 21
`wherein the power supply
`generates a constant power.
`
`23. The apparatus of claim 21
`wherein the power supply
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`Mozgrin’s pulse.
`
`If one of ordinary skill, applying Mozgrin’s power levels
`did not experience Kudryavtsev’s “explosive increase” in
`plasma density, it would have been obvious to adjust the
`operating parameters, e.g., increase the pulse length and/or
`pressure, so as to trigger Kudryavtsev’s fast stage of
`ionization. One of ordinary skill would have been
`motivated to use Kudryavtsev’s fast stage of ionization in
`Mozgrin so as to increase plasma density and thereby
`increase the sputtering rate. Further, use of Kudryavtsev’s
`fast stage in Mozgrin would have been a combination of
`old elements that yielded predictable results of increasing
`plasma density and multi-step ionization.
`
`Background:
`Ohring at 104 (“Microscopically, positive gas ions in the
`discharge strike the cathode plate and eject neutral target
`atoms…. In addition, other particles (secondary electrons,
`desorbed gases, and negative ions) … are emitted from the
`target.”)
`The combination of Mozgrin and Kudryavstev discloses
`the power supply generates a constant power.
`
`See evidence cited in claim 21.
`
`‘142 Patent at Fig. 4
`
`‘142 Patent at 12:47-51
`
`‘142 Patent, 12:66-67(“Between time t1 and time t2, the
`voltage 326, the current 328, and the power 330 remain
`constant….”)
`
`Mozgrin at Fig. 3
`
`Mozgrin, at 402, right col ¶2 (“Figure 3 shows typical
`voltage and current oscillograms of the quasi-stationary
`discharge.”)
`
`The combination of Mozgrin and Kudryavstev discloses
`the power supply generates a constant voltage.
`
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`generates a constant voltage.
`
`See evidence cited in claim 21.
`
`Mozgrin at Fig. 3
`
`25. The apparatus of claim 21
`wherein the electric field
`comprises a pulsed electric field.
`
`The combination of Mozgrin and Kudryavstev discloses
`the electric field comprises a pulsed electric field.
`
`Mozgrin at Figs. 1, 3
`
`26. The apparatus of claim 21
`wherein a rise time of the
`electric field is chosen to
`increase an ionization rate of the
`excited atoms in the weakly-
`ionized plasma.
`
`Mozgrin, at 401, Fig. 1 caption, (“Fig. 1. Discharge device
`configurations: (a) planar magnetron;”)
`
`Mozgrin, at 403-404, right col, last paragraph of 403, left
`col, first paragraph of 404 (“The current pulse … repetition
`frequency was 10 Hz...”)
`
`The combination of Mozgrin and Kudryavstev discloses a
`rise time of the electric field is chosen to increase an
`ionization rate of the excited atoms in the weakly-ionized
`plasma.
`
`See evidence cited in claim 21.
`
`Kudryavtsev at Fig. 1
`
`Mozgrin at 401, ¶ spanning left and right columns (“The
`frequency parameters of the pulsed supply unit were
`chosen in accordance with the increase in time of the
`quasi-stationary plasma density formation and the times of
`the ionization instability and ionization-overheating
`instability development. Designing the unit, we took into
`account the dependences which had been obtained in [8] of
`ionization relaxation on pre-ionization parameters,
`pressure, and pulse voltage amplitude. In addition, we
`allowed for the fact that the development time for the
`ionization-overheating instability was about 10-3 - 3 x 10-3
`s in the pressure range up to 0.5 torr [9]. Thus, the supply
`unit was made providing square voltage and current pulses
`with raise times (leading edge) of 5 - 60 μs and durations
`of as much as 1.5 ms. Short-circuit current amplitude was
`up to 3 kA; no-load voltage was as much as 2.4 kV.”)
`
`Mozgrin at 401, right col, ¶ 1 (“[t]he power supply was
`able to deliver square voltage and current pulses with [rise]
`
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`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`27. The apparatus of claim 21
`wherein the strongly-ionized
`plasma is substantially uniform
`proximate to the cathode.
`
`28. The apparatus of claim 21
`wherein a dimension of the gap
`between the anode and the
`cathode is chosen to increase an
`ionization rate of the excited
`atoms in the weakly-ionized
`plasma.
`
`29. The apparatus of claim 21
`wherein the ionization source is
`chosen from the group
`comprising an electrode coupled
`to a DC power supply, an
`electrode coupled to an AC
`power supply, a UV source, an
`X-ray source, an electron beam
`source, an ion beam source, an
`inductively coupled plasma
`source, a capacitively coupled
`plasma source, and a microwave
`plasma source.
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`times (leading edge) of 5 – 60 µs ….”)
`
`The combination of Mozgrin and Kudryavstev discloses
`the strongly-ionized plasma is substantially uniform
`proximate to the cathode.
`
`See evidence cited in claim 21.
`
`Mozgrin, at 403, left col, last ¶ (“…being transferred to the
`high-current regime, the discharge expands over a
`considerably larger area of the cathode surface than it
`occupied in the stationary pre-ionization regime.”)
`
`The combination of Mozgrin and Kudryavstev discloses a
`dimension of the gap between the anode and the cathode is
`chosen to increase an ionization rate of the excited atoms
`in the weakly-ionized plasma.
`
`See evidence cited in claim 21.
`
`See evidence cited in claim 26.
`
`The combination of Mozgrin and Kudryavtsev discloses
`the ionization source is chosen from the group comprising
`an electrode coupled to a DC power supply, an electrode
`coupled to an AC power supply, a UV source, an X-ray
`source, an electron beam source, an ion beam source, an
`inductively coupled plasma source, a capacitively coupled
`plasma source, and a microwave plasma source.
`
`See evidence cited in claim 21.
`
`Mozgrin at 401, left col, ¶ 5 (“…The pre-ionization system
`provided direct current up to 0.3A and voltage up to 3
`kV.”) (emphasis added)
`
`Mozgrin at Figs. 1 and 2
`
`30. The apparatus of claim 21
`further comprising a magnet that
`is positioned to generate a
`magnetic field proximate to the
`weakly-ionized plasma, the
`magnetic field trapping electrons
`
`The combination of Mozgrin and Kudryavstev discloses a
`magnet that is positioned to generate a magnetic field
`proximate to the weakly-ionized plasma, the magnetic field
`trapping electrons in the weakly-ionized plasma proximate
`to the cathode.
`
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`in the weakly-ionized plasma
`proximate to the cathode.
`
`[31pre]. A method for generating
`a strongly-ionized plasma, the
`method comprising:
`
`[31a] ionizing a feed gas to
`generate a weakly-ionized
`plasma proximate to a cathode,
`the weakly-ionized plasma
`reducing the probability of
`developing an electrical
`breakdown condition proximate
`to the cathode;
`[31b] and applying an electric
`field across the weakly-ionized
`plasma in order to excite atoms
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`See evidence cited in claim 21.
`
`‘142 Patent at 1:41-43 [in the Background of the
`Invention] (“Magnetron sputtering systems use magnetic
`fields that are shaped to trap and concentrate secondary
`electrons…”)
`
`Mozgrin at Fig. 1
`
`Mozgrin at 401, left col, ¶ 1 (“The electrodes were
`immersed in a magnetic field of annular permanent
`magnets.”)
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had
`an annular shape and was adjacent to the cathode.”)
`(emphasis added)
`
`Mozgrin at 401, right col, ¶2 (“We found out that only the
`regimes with magnetic field strength not lower than 400 G
`provided the initial plasma density in the 109-1011 cm-3
`range.”)
`
`Mozgrin at 407, left col, ¶ 3 (“The action of the magnetic
`field serves only to limit the electron thermal conductivity
`and to provide collisions sufficient for efficient energy
`transfer from electrons to heavy particles.”) (emphasis
`added)
`
`The combination of Mozgrin and Kudryavstev discloses a
`method for generating a strongly-ionized plasma.
`
`See evidence cited in limitation [21pre] of claim 21.
`
`The combination of Mozgrin and Kudryavstev discloses
`ionizing a feed gas to generate a weakly-ionized plasma
`proximate to a cathode, the weakly-ionized plasma
`reducing the probability of developing an electrical
`breakdown condition proximate to the cathode.
`
`See evidence cited in limitation [21c] of claim 21.
`
`The combination of Mozgrin and Kudryavstev discloses
`applying an electric field across the weakly-ionized plasma
`in order to excite atoms in the weakly-ionized plasma and
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`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`in the weakly-ionized plasma
`and to generate secondary
`electrons from the cathode, the
`secondary electrons ionizing the
`excited atoms, thereby creating
`the strongly-ionized plasma.
`33. The method of claim 31
`wherein the applying an electric
`field comprises applying the
`electric field at a constant power.
`
`34. The method of claim 31
`wherein the applying an electric
`field comprises applying the
`electric field at a constant
`voltage.
`
`35. The method of claim 31
`wherein the applying the electric
`field comprises applying an
`electrical pulse across the
`weakly-ionized plasma.
`
`Mozgrin in view of Kudryavtsev
`
`to generate secondary electrons from the cathode, the
`secondary electrons ionizing the excited atoms, thereby
`creating the strongly-ionized plasma.
`
`See evidence cited in limitation [21d] of claim 21.
`
`The combination of Mozgrin and Kudryavstev discloses
`the applying an electric field comprises applying the
`electric field at a constant power.
`
`See evidence cited in claim 31.
`
`‘142 Patent at Fig. 4
`
`‘142 Patent at 12:47-51
`
`‘142 Patent, 12:66-67(“Between time t1 and time t2, the
`voltage 326, the current 328, and the power 330 remain
`constant….”)
`
`Mozgrin at Fig. 3
`
`Mozgrin, at 402, right col ¶2 (“Figure 3 shows typical
`voltage and current oscillograms of the quasi-stationary
`discharge.”)
`
`The combination of Mozgrin and Kudryavstev discloses
`the applying an electric field comprises applying the
`electric field at a constant voltage.
`
`See evidence cited in claim 31.
`
`Mozgrin at Fig. 3
`
`The combination of Mozgrin and Kudryavstev discloses
`the applying the electric field comprises applying an
`electrical pulse across the weakly-ionized plasma.
`
`See evidence cited in claim 31.
`
`Mozgrin at Figs. 1, 2, 3
`
`Mozgrin at 402, right col, ¶ 2 (“Part 1 in the voltage
`oscillogram represents the voltage of the stationary
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`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`36. The method of claim 35
`further comprising selecting at
`least one of a pulse amplitude
`and a pulse width of the
`electrical pulse in order to
`increase an ionization rate of the
`strongly-ionized plasma.
`
`37. The method of claim 35
`further comprising selecting at
`least one of a pulse amplitude
`and a pulse width of the
`electrical pulse in order to cause
`the strongly-ionized plasma to be
`substantially uniform in an area
`adjacent to a surface of the
`cathode.
`
`38. The method of claim 31
`wherein the strongly-ionized
`plasma is substantially uniform
`proximate to the cathode.
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`discharge (pre-ionization stage).”)
`
`Mozgrin at 401, right col, ¶ 1 (“Thus, the supply unit was
`made providing square voltage and current pulses with
`[rise] times (leading edge) of 5 – 60 µs…”)
`
`The combination of Mozgrin and Kudryavstev discloses
`selecting at least one of a pulse amplitude and a pulse
`width of the electrical pulse in order to increase an
`ionization rate of the strongly-ionized plasma.
`
`See evidence cited in claim 35.
`
`Mozgrin at Figs. 1, 2, 3
`
`Mozgrin at 402, right col, ¶ 2 (“Part 1 in the voltage
`oscillogram represents the voltage of the stationary
`discharge (pre-ionization stage).”)
`
`Mozgrin at 401, right col, ¶ 1 (“Thus, the supply unit was
`made providing square voltage and current pulses with
`[rise] times (leading edge) of 5 – 60 µs…”)
`
`The combination of Mozgrin and Kudryavstev discloses
`selecting at least one of a pulse amplitude and a pulse
`width of the electrical pulse in order to cause the strongly-
`ionized plasma to be substantially uniform in an area
`adjacent to a surface of the cathode.
`
`See evidence cited in claim 35.
`
`Mozgrin, at 403, left col, last ¶ (“…being transferred to the
`high-current regime, the discharge expands over a
`considerably larger area of the cathode surface than it
`occupied in the stationary pre-ionization regime.”)
`
`The combination of Mozgrin and Kudryavstev discloses
`wherein the strongly-ionized plasma is substantially
`uniform proximate to the cathode.
`
`See evidence cited in claim 31.
`
`Mozgrin, at 403, left col, last ¶ (“…being transferred to the
`high-current regime, the discharge expands over a
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`39. The method of claim 31
`further comprising generating a
`magnetic field proximate to the
`weakly-ionized plasma, the
`magnetic field trapping electrons
`in the weakly-ionized plasma.
`
`[41pre.] An apparatus for
`generating a strongly-ionized
`plasma, the apparatus
`comprising:
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`considerably larger area of the cathode surface than it
`occupied in the stationary pre-ionization regime.”)
`
`The combination of Mozgrin and Kudryavtsev discloses
`generating a magnetic field proximate to the weakly-
`ionized plasma, the magnetic field trapping electrons in the
`weakly-ionized plasma.
`
`See evidence cited in claim 31.
`
`‘142 Patent at 1:41-43 [in the Background of the
`Invention] (“Magnetron sputtering systems use magnetic
`fields that are shaped to trap and concentrate secondary
`electrons…”)
`
`‘142 Patent at 1:37-40 (“The plasma is replenished by
`electron-ion pairs formed by the collision of neutral
`molecules with secondary electrons generated at the target
`surface.”)
`
`Mozgrin at Fig. 1
`
`Mozgrin at 401, left col, ¶ 1 (“The electrodes were
`immersed in a magnetic field of annular permanent
`magnets.”)
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had
`an annular shape and was adjacent to the cathode.”)
`
`Mozgrin at 401, right col, ¶2 (“We found out that only the
`regimes with magnetic field strength not lower than 400 G
`provided the initial plasma density in the 109-1011 cm-3
`range.”)
`
`Mozgrin at 407, left col, ¶ 3 (“The action of the magnetic
`field serves only to limit the electron thermal conductivity
`and to provide collisions sufficient for efficient energy
`transfer from electrons to heavy particles.”)
`
`The combination of Mozgrin and Kudryavstev discloses an
`apparatus for generating a strongly-ionized plasma.
`
`‘142 Patent at claim 18 (“wherein the peak plasma density
`of the strongly-ionized plasma is greater than about
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`[41a.] means for ionizing a feed
`gas to generate a weakly ionized
`plasma proximate to a cathode,
`the weakly ionized plasma
`reducing the probability of
`developing an electrical
`breakdown condition proximate
`to the cathode; and
`
`1012 cm˗3”)
`
`Mozgrin at Fig 1
`
`Mozgrin at 400, right col, ¶ 4 (“To study the high-current
`forms of the discharge, we used two types of devices: a
`planar magnetron and a ystem with specifically shaped
`hollow electrodes.”)
`
`Mozgrin at 401, right col, ¶2 (“For pre-ionization … the
`initial plasma density in the 109 – 1011 cm-3 range.”)
`
`Mozgrin at 409, left col, ¶ 4 (“The implementation of the
`high-current magnetron discharge (regime 2) in sputtering
`… plasma density (exceeding 2x1013 cm-3).”)
`
`Mozgrin at 409, left col, ¶5 (“The high-current diffuse
`discharge (regime 3) is useful for producing large-volume
`uniform dense plasmas ni  1.5x1015cm-3…”).
`
`The combination of Mozgrin and Kudryavtsev discloses
`means for ionizing a feed gas to generate a weakly ionized
`plasma proximate to a cathode, the weakly ionized plasma
`reducing the probability of developing an electrical
`breakdown condition proximate to the cathode.
`
`Claimed function
`
`Claim 41 recites “means for ionizing a feed gas to generate
`a weakly ionized plasma proximate to a cathode, the
`weakly ionized plasma reducing the probability of
`developing an electrical breakdown condition proximate to
`the cathode.”
`
`The combination of Mozgrin and Kudryavtsev teach the
`function corresponding to the “means for ionizing…”
`limitation.
`
`‘142 Patent at 5:18-19 (“The weakly-ionized plasma is also
`referred to as a pre-ionized plasma.”)
`
`‘142 Patent at claim 17 (“wherein the peak plasma density
`of the weakly-ionized plasma is less than about 1012 cm˗3”)
`
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`Mozgrin at Figs. 1, 2, 6, 7
`
`Mozgrin at 402, right col, ¶2 (“Figure 3 shows typical
`voltage and current oscillograms.… Part I in the voltage
`oscillogram represents the voltage of the stationary
`discharge (pre-ionization stage).”)
`
`Mozgrin at 401, right col, ¶2 (“[f]or pre-ionization, we
`used a stationary magnetron discharge; … provided the
`initial plasma density in the 109 – 1011 cm˗3 range.”)
`
`Mozgrin at 400, right col, ¶ 3 (“We investigated the
`discharge regimes in various gas mixtures at 10-3 – 10
`torr…”)
`
`402, ¶ spanning left and right cols (“We studied the high-
`current discharge in wide ranges of discharge current…and
`operating pressure…using various gases (Ar, N2, SF6, and
`H2) or their mixtures of various composition…”)
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had
`an annular shape and was adjacent to the cathode.”)
`
`Mozgrin at 406, right col, ¶3 (“pre-ionization was not
`necessary; however, in this case, the probability of
`discharge transferring to arc mode increased.”)
`
`Mozgrin at 400, left col, ¶ 3 (“Some experiments on
`magnetron systems of various geometry showed that
`discharge regimes which do not transit to arcs can be
`obtained even at high currents.”)
`
`Corresponding structure
`
`The ‘142 Patent discloses the following structure that
`corresponds to the means for ionizing:
`
` power supply, generating the voltage, current and power
`values shown in Fig. 4 (e.g., between t1 – t2 and t6 – t7),
`electrically coupled to cathode (e.g., 204), anode (e.g.,
`216) and/or an electrode (e.g., 452, 452’), wherein the
`cathode, anode and/or electrode are arranged relative to a
`sputtering target as shown in Figs. 2A-2D and 6A-6D, and
`
` a
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`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`[41b.] means for applying an
`electric field across the weakly
`ionized plasma in order to excite
`atoms in the weakly ionized
`plasma and to generate
`secondary electrons from the
`cathode, the secondary electrons
`ionizing the excited atoms,
`thereby creating the strongly-
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`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`as described in the text of the ‘142 Patent at 5:5-36, 16:24-
`40, 17:40-18:12, 18:13-34, and 18:35-46.
`
`The combination of Mozgrin and Kudryavstev discloses
`the structure corresponding to the “means for ionizing…”
`limitation. For example:
`
`Mozgrin at Figs. 1, 2, 3.
`
`
`Mozgrin at 401, right col, ¶2 (For pre-ionization, we used a
`stationary magnetron discharge … provided the initial
`plasma density in the 109 – 1011 cm-3 range.)
`
`Mozgrin at 406, right col, ¶3 (“pre-ionization was not
`necessary; however, in this case, the probability of
`discharge transferring to arc mode increased.”)
`
`Mozgrin at 401, left col, ¶ 1 (“The [plasma] discharge had
`an annular shape and was adjacent to the cathode.”)
`(emphasis added)
`
`Any differences between Mozgrin’s and the ‘142 patent’s
`mechanical arrangement of the anode and cathode is
`nothing more than the mechanical rearrangement of well-
`known components. Rearranging Mozgrin’s components
`to match that of the ‘142 patent would be obvious to one of
`ordinary skill.
`
`Background:
`Manos at 231 (“arcs…are a problem…” )
`
`The combination of Mozgrin and Kudryavtsev discloses
`means for applying an electric field across the weakly
`ionized plasma in order to excite atoms in the weakly
`ionized plasma and to generate secondary electrons from
`the cathode, the secondary electrons ionizing the excited
`atoms, thereby creating the strongly-ionized plasma.
`
`Claimed function
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`

`
`
`‘142 Claims 21-23, 25-30, 31,
`33-39, 41, and 43
`
`ionized plasma.
`
`EXHIBIT D.01
`U.S. Patent No. 6,853,142
`
`Mozgrin in view of Kudryavtsev
`
`Claim 41 recites “means for applying an electric field
`across the weakly ionized plasma in order to excite atoms
`in the weakly ionized plasma and to generate secondary
`electrons from the cathode, the secondary electrons
`ionizing the excited atoms, thereby creating the strongly-
`ionized plasma.”
`
`The combination of Mozgrin and Kudryavtsev teach the
`function corresponding to the “means for applying …”
`
`‘142 Patent at 1:41-43 (“Magnetron sputtering systems use
`magnetic fields that are shaped to trap and to concentrate
`secondary electrons, which are produced by ion
`bombardment of the target surface.”)
`
`‘142 Patent at 1:37-40 (“The plasma is replenished by
`electron-ion pairs formed by the collision of neutral
`molecules with secondary electrons generated at the target
`surface.”)
`
`Mozgrin at Figs. 1, 2, 3
`
`Mozgrin at 402, right col, ¶ 2 (“Part 1 in the voltage
`oscillogram represents the voltage of the stationary
`discharge (pre-ionization stage).”)
`
`Mozgrin at 401, right col, ¶ 1 (“Thus, the supply unit was
`made providing square voltage and current pulses with
`[rise] times (leading edge) of 5 – 60 µs…”)
`
`Mozgrin at 401, ¶ spanning left and right cols (“[d]esigning
`the [pulsed supply] unit, we took into account the
`dependences which had been obtained in [Kudryavtsev] of
`ionization relaxation on pre-ionization parameters,
`pressure, and pulse voltage amplitude.”)
`
`Kudryavtsev at Figs. 1, 6
`
`Kudr